The Gambling Commission has now published their response to the remote gambling and software technical standards (RTS) consultation, along with a new version of the RTS. As we reported back in January in Online Gambling Lawyer, some of the proposals put forward in the consultation were set to be far-ranging. Whilst the Commission’s approach has been tempered in some respects in the wake of the responses received, operators will still need to make an array of technical changes to ensure compliance.
The full response document includes a summary of the responses as well as the Commission’s final position on each proposal. The Commission has also published the updated RTS in line with its responses. Either the new requirements come into effect immediately, on 1 October 2017 or 1 April 2018 depending on the development work required.
Key changes to the RTS include the following:
- Customers must have immediate access to three months’ account and gambling history without having to contact the licensee. This is a departure from the 12 months’ originally proposed by the Commission. A minimum of 12 months’ history must, however, be made available on request.
- When displaying account history, licensees are now required to calculate and display each customer’s win/loss total for the selected time period (as chosen by the customer) on the same page. Where account history is displayed across multiple pages the win/loss total for the defined period must be provided somewhere on the first page/screen.
- Details of the customer’s net deposits (being the running total of all deposits minus the sum of all withdrawals over the lifetime of the account) must be made available to the customer. As a minimum, this figure should represent net deposits from the implementation date of 1 April 2018.
- Customers must be given the choice as to whether to accept price movements in either direction on bets placed. This inclusion is a result of the Commission’s concerns that bets may be subject to price fluctuations caused by time delays or market movements (in particular for fast moving events, such as in-play betting or live-sporting events). This option must be presented on a per bet basis unless the customer has requested a default setting to disable price change alerts. Where a customer chooses not to accept price changes automatically, any bet where the price changes must be reoffered before it is accepted.
- Numerous changes in respect of linked progressive jackpots have been introduced, including informing players of the likelihood of winning a jackpot and making it clear when a player is not eligible to win a jackpot.
- Operators can vary the RTP of play-for-fun games but only where this corresponds with the equivalent play-for-money game offered on the same customer facing website/app.
- Various new requirements have been introduced in respect of peer-to-peer poker, including requirements that licensees keep accurate records of all accounts that are closed following an investigation into prohibited gambling activity, set out a description of the licensee’s policy for dealing with funds recovered from players in integrity cases, use gameplay analysis to detect unusual behaviour where it is appropriate to do so, monitor the effectiveness of policies and procedures designed to detect and prevent collusion, and to report any accounts that are closed for suspicious or irregular play
- Customers must now have the option to set account-level financial limits (previously the RTS simply stated that limits could be implemented across all products or individual products).
- A set of standards for providers of live dealer studios that have not been audited by other jurisdictions has been introduced.